July 17, 2017
Clients and Friends,
The CFPB issued its final rule to amend TRID on July 7, 2017, almost one year after the CFPB issued its proposal. The CFPB stated that, “[t]his final rule will generally benefit consumers and industry alike by providing greater clarity for implementation going forward.” The final rule, which has been commonly referred to as “TRID 2.0,” finalized many of the proposed changes that would have affected the scope of the rule and the completion of the Loan Estimate (“LE”) and Closing Disclosure (“CD”) for particular loan transactions, but it did not finalize some of the most controversial proposed changes in the CFPB’s proposal. The press release and final rule are available at: https://www.consumerfinance.gov/about-us/newsroom/cfpb-finalizes-updates-know-you-owe-mortgage-disclosure/.
Weighing in at 560 pages, there is certainly a great deal of information in this rule for industry to review and implement. In addition, the final rule has some surprising changes and raises some new questions.
I have drafted a detailed summary of the final rule, which includes some of my thoughts on the changes. Please contact me if you would like to obtain a copy of the summary.